Compliance

At Fresenius, integrity and ethical conduct govern the activities of our operations. 
Guided by our comprehensive Code of Conduct, we are fully committed to compliance with laws, internal guidelines, and ethical standards. 

Our Code, endorsed by the Group Management Board, serves as a universal framework for behavior across the Fresenius Group, applying to all employees, including management at every level. It encompasses principles aligned with recognized international regulations and is customized within each business segment to reflect its unique characteristics. Integral to our employment contracts, the Code ensures all our employees uphold the applicable standards of conduct. In addition, the business segments implemented their own Codes of Conduct which are adapted to the individual characteristics of each business segment. Furthermore, our commitment extends to regulating political activities, ensuring our employees adhere to both our ethical framework and legal standards. 

Through mandatory training, including aspects of human rights, we ensure every employee at Fresenius is committed to the principles laid out in our Code of Conduct.
 

At Fresenius, we uphold the applicable standards not only within our operations but across our supply chain. Our revised Code of Conduct for Business Partners, enriched with human rights considerations and aligned with the German Act on Corporate Due Diligence Obligations in Supply Chains (LkSG), sets clear expectations for ethical conduct towards business partners and suppliers. This Code mandates compliance with all applicable laws and explicitly prohibits corruption and bribery, aligning with both national and international anti-corruption laws. Our commitment extends to ensuring transparency in interactions with healthcare professionals.

Prior to initiating any business relationship, we inform our partners about these requirements and conduct risk-based due diligence. Our Codes of Conduct are publicly accessible, reflecting our transparency and commitment to ethical business practices.

Furthermore, our commitment to human rights extends beyond our own operations. Through our Human Rights Program, we select suppliers and business partners who respect human rights within their value chains.

This commitment reflects our values and the care we extend to our patients and over 190,000 employees worldwide.
 

At Fresenius, our Compliance Management System (CMS) is aligned with the activity of our business segments, designed to proactively prevent corruption and bribery within our business environment. Tailored to the needs of our business segments, our CMS aspire to integrate a deep understanding of compliance into our daily operations. 

Our system is built risk-oriented on the pillars of prevention, detection, and response, aiming to embed a living compliance culture across all levels of our organization. This culture is not static but evolves through continuous improvement and active exchange of best practices across our segments. The business segments develop operational goals and measures on an annual basis to continuously strengthen the compliance management system.

The Group function Risk & Integrity advises the corporate functions, sets minimum standards for the compliance management system Group-wide, and manages the Group-wide compliance reporting.

The Risk Steering Committee (RSC) – under the management of the ESG Board member – discusses internal and external developments regarding the risk management and internal control system as an advisory body. This includes, for example, developments relevant for the compliance management system.

The Group Chief Compliance Officer, the Chief Compliance Officers, or Heads of Compliance of each business segment and the Head of Group Reporting & Monitoring form the Group Compliance Management Team (GCMT). This management team meets on a monthly basis and sets the governance standards for compliance at Fresenius and supports the effective implementation of the compliance management system. The GCMT regularly examines the results of the compliance risk analysis, the compliance figures, the further development of the compliance management system and the results of monitoring measures.

The design and implementation of our compliance management system is based on international regulations and guidelines, such as the ISO standards on the setup of compliance management systems and applicable audit standards of the Institute of Public Auditors in Germany, Incorporated Association IDW (PS 980). When implementing measures, we take into account the respective national or international legal frameworks. In addition, a law firm reviewed the design of the Corporate CMS and concluded that it is organizationally effectively anchored and programmatically appropriately designed.

Post-acquisition, we quickly integrate new entities into our compliance framework, ensuring our standards are uniformly applied.
 

At Fresenius, upholding our ethical standards and compliance is central to our business. We empower our employees and external stakeholders to voice concerns about potential misconduct, including violations of laws, regulations, or our internal guidelines. Our comprehensive and confidential reporting system is accessible globally, supporting submissions in over 30 languages through various channels. Reports can be made by name or anonymously at any time of the day.

Incoming reports are treated confidentially and are taken seriously. Each report is carefully evaluated for its plausibility and potential impact. Our specialized teams, supported by ombudsperson panels at both Group and business segment levels, ensure thorough comprehensive investigations, drawing on both internal and external expertise as necessary.
Actions are promptly taken by the responsible management in collaboration with compliance officers, guided by the severity and nature of the misconduct. 

Our approach not only addresses immediate concern but also strengthens our processes to prevent future issues.

Measures are implemented in a timely manner by the responsible management in close cooperation with the compliance officers. Depending on the type and severity of the misconduct, disciplinary sanctions or remedies under civil or criminal law may be imposed. After completion of the investigation, we use the results of internal reviews and reports to review our business processes. We implement corrective or improvement measures where necessary to prevent similar misconduct in the future.

Compliance cases are evaluated based on the Group-wide policies as well as on those of the business segments, which comply with the Group-wide policies. 

For anyone wishing to report a concern or seek advice, the Fresenius Risk & Integrity team is easily reachable:

Online Reporting Platform: https://www.bkms-system.net/fse-compliance

Toll-Free Number: +49 (0) 800-1401519

Direct Line: +49 (0) 30-58943054 

The whistleblowing system can be used for reports concerning Fresenius Management SE, Fresenius SE & Co. KGaA, and Fresenius Digital Technology GmbH and Fresenius Versicherungsvermittlungs GmbH. Please address reports for Fresenius Kabi, Fresenius Helios, Fresenius Medical Care or Fresenius Vamed to the relevant business segment.

These channels ensure that reaching out is straightforward, secure, and supportive for all.
Only acting in an exemplary fashion enables us to maintain our integrity and the trust of our colleagues and partners. Every one of us is responsible for our personal behavior.

Thank you for your support and commitment to compliance at Fresenius.
 

The tax strategy of Fresenius Group is aligned with our core values: Wellbeing of patients, Quality, Integrity, Responsibility and Reliability. 

The tax compliance objectives are aimed at safeguarding compliance with all tax laws and reporting obligations and enhancing shareholder value based on the following principles:

1. We strive to maintain a culture that ensures that all people in our organization are aware that observing rules and the correct handling of tax matters is essential to the Fresenius Group.

2. The Fresenius Corporate Tax department and the other segment tax functions in the group are creating awareness of tax compliance in the Fresenius Group which is implemented in the Code of Conduct. This includes providing appropriate information and training to employees who perform tax-related tasks. The respective rules and procedures of this tax compliance objectives have been adopted by the Management Board. 

3. We have to ensure that all applicable tax laws and reporting obligations are observed in a comprehensive and timely manner and that tax affairs are managed responsibly and transparently. We maintain an internal control system that meets existing standards and ensures that we comply with the tax and reporting obligations in all jurisdictions where we do our business. Appropriate processes and efficient controls shall safeguard that tax risks are identified, systematically recorded and assessed considering their probability of occurrence and potential financial exposure and reported in our external financial reporting. 

4. Fresenius Corporate Tax department acts as a central point of contact for all Group tax functions, providing support and advice. Together they act as partners of the operating business units rendering attention, support and advice for transactions as well as for day-to-day business. In addition, the Fresenius Corporate Tax department also performs in whole or in part the tax function for some business segments.

5. Complying with applicable tax laws and upholding our reputation with governmental authorities and the public, we support the relevant business processes as well as sustainable growth of shareholder value with efficient tax planning. We don´t engage in tax arrangements without business purpose or commercial rationale. We routinely seek external professional guidance to reduce uncertainty when required.

6. Intercompany transfer pricing policies are set in accordance with arm’s length’s principles following international standards, i.e. taxes have to be paid on profits according to where value is created.

7. Communication and cooperation regarding tax issues is organized in a way that safeguards that all information is managed in a timely and appropriate manner. Tax is part of the internal control system and Risk Reporting. The FSE Group Chief Financial Officer (“CFO”) will be informed about all relevant tax matters and the development of tax risks. The Fresenius Corporate Tax department reports regularly to the CFO. The responsible CFOs ensures adequate resources for the tax function.

8. We support a cooperative, honest and respectful approach with tax authorities and other public bodies which we consider essential for efficient tax compliance and risk management.

9. We support initiatives such as the initiatives of the Organization for Economic Cooperation and Development (“OECD”) regarding Cooperative Compliance (whereby tax authorities and taxpayers benefit equally from more transparency) and Base Erosion and Profit Shifting (“BEPS”). 

10. We continuously monitor changes in tax laws and practice. We recognize the importance of participating in discussions on the development of new tax legislation either directly or through the respective interest groups.

11. We are committed to employing and retaining excellent tax professionals long-term. We continuously work on our employer attractiveness, taking into account personal skills and providing a professional environment for personal development.